OUNO App (UK) Limited (together with its affiliates companies – “OUNO”, “we”, “our” or “us”) puts great efforts in making sure that your personal data is kept safe and used properly.

This Privacy Policy describes how, with respect to OUNO App’s technology platform services (the “Services”), we collect, store, use and disclose the following types of personal data:

1. User data relating to individuals who are registered to the Services and use them either independently or on behalf of our corporate customers, to book, send and receive taxi rides and courier deliveries;
2. Driver and courier data relating to drivers and couriers who use the Services, either individually or as part of a fleet that has integrated into the Services, to accept and execute rides and/or delivery orders, pick up riders or deliveries and carry them to their destinations, and to receive payments for such activities;
3. Website visitor, CRM & prospects data relating to visitors of our website, participants at our events, business customers, partners, and any prospective customer, partner, user or driver who visits or otherwise interacts with any of our websites, online ads and content, emails or other communications under our control (“Sites”).

Specifically, this Privacy Policy describes our practices regarding –

1. Data Collection
2. Data uses
3. Data Location and Retention
4. Data Sharing
5. Cookies and Tracking Technologies
6. Communications
7. Data Security
8. Data Subject Rights
9. Data Controller/Processor
10.  Additional Notice And Contact

 

If you are user, driver, visitor, partner or prospect (“you”) – please read this Privacy Policy carefully and make sure that you fully understand and agree to it. 

You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined below), please refrain from accessing, using or registering to our Services. If you are using the Services on behalf of any of our business customers or partners, we suggest that you contact your organisational account administrator with any questions or to let them know that you would not like to be registered by them to the Services.

 

1. Data Collection

(i) User Data: Our Services enable OUNO App business customers and their personnel, as well as any other eligible individuals, to easily book and manage their business or personal ground travel and deliveries. OUNO App collects and generates the following types of personal data relating to such business or individual users –

• user profile information (name, e-mail address, mobile phone number, saved addresses, and, where applicable, hashed password);
• business account information (as applicable: company name, industry, account classification and commercial terms);
• orders, transactions and ride/delivery details (ride and delivery orders, pick-up and drop-off data, route, GPS location of mobile device, contact details for delivery sender and recipient, payment method, invoices and transaction history, ride/delivery preferences, and additional details provided by the user with respect to the order);
• rider, driver and courier ratings (as submitted by the user or its driver/courier, respectively);
• usage information (connectivity, technical and aggregated usage data and activity logs, log-in and log-out time, user agent, IP addresses, device and mobile app data (like type, OS, device id, app version, browser version, locale, time-zone and language settings used), session recordings and analytics, and the cookies and pixels installed or utilized on their device);
• direct interactions and communications with us (including recordings and transcripts of your calls, emails, form submissions and chats with us, e.g. for customer service, user enablement, feedback, support and training purposes).
• contact list If you give us permission to use your phone’s phone book / contacts, then ability to share address information from your telephone’s contact book is supported

OUNO App processes certain limited business user data on its customers’ behalf, as their ‘data processor’ (namely, such data which is needed for registering and deregistering users on such customers’ business account); whilst with respect to all other personal data pertaining to our users and processed by OUNO App, OUNO App shall act and be deemed as the ‘data controller’.

(ii) Driver and Courier Data: Our Services enable registered taxi drivers and delivery couriers – either operating independently or as part of our partner fleets – to easily accept taxi rides and delivery orders. OUNO App collects and generates the following types of personal data relating to such drivers and couriers –

• driver/courier information (name, e-mail address, mobile phone number, hashed password, subscription forms and details, ID, driver and taxi licenses, vehicle details, submitted hobby);
• fleet account information (where applicable: company name, account classification and commercial terms);
• billing and financial details (where applicable: bank account and related payment details, invoices and transaction history, tax forms);
• orders, transactions and ride/delivery details (ride and delivery orders accepted and performed, pick-up and drop-off data, route, GPS location of mobile device, contact details for delivery sender and recipient, ride/delivery preferences, shift preferences, and additional details provided by the driver/courier in the course of their use of the Services);
• rider, driver and courier ratings (as submitted by the driver/courier or the users, respectively);
• usage information (connectivity, technical and aggregated usage data and activity logs, log-in and log-out time, user agent, IP addresses, device and mobile app data (like type, OS, device id, app version, browser version, locale, time-zone and language settings used), session recordings and analytics, and the cookies and pixels installed or utilized on their device);
• direct interactions and communications with us (including recordings and transcripts of your calls, emails, form submissions and chats with us, e.g. for user enablement, feedback, support and training purposes).

(iii) Sites, CRM & Prospect Data: We collect and generate the following types of personal data concerning our website visitors, customers, partners and prospects –

• Sites usage information (connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, and the cookies and pixels installed or utilized on our Sites and/or their device);
• Business account information (contact, contractual and billing details concerning our business customers and partners, which may also contain the details of their internal focal persons who directly engage with OUNO App on behalf of their organization, e.g. the account administrators, billing contacts and authorized signatories on behalf of the customer or partner; as well as the needs and preferences of the customer or partner, as identified to us or recognized through our engagement with them);
• Information concerning our prospects (contact and business details, our communications with such customers and prospects (correspondences, call and video recordings, call transcripts, and analyses thereof), as well as any needs, preferences, attributes and insights relevant to our potential engagement).

We collect such data either automatically, through the data subject’s interaction with us or with our Sites or Services; or through third party services, social media, analytics tools, events we organize or participate in, and other business initiatives.

To the extent that any of the above-mentioned data only pertains to a non-human entity (e.g., the phone number or bank account of a company or business), we will not regard it as “personal data” and this Privacy Policy will not apply to it.

 

1. Data Uses

We use personal data as necessary for the facilitation and performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Services; providing customer service and technical support; and protecting and securing our users, customers, partners, ourselves and our Services.

If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by or via the Services, e.g. ‘special categories’ under the GDPR), your acceptance of our Terms and Conditions and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy. If you wish to revoke such consent, please contact us at privacy@ounoapp.com

Specifically, we use personal data for the following purposes:

1. To facilitate, operate, and provide our Services;
2. To authenticate the identity of our users, drivers and couriers, and to allow them to access and use our Services;
3. To provide assistance and support to our customers, users, drivers and couriers;
4. To gain a better understanding on how you use and interact with our Services, and how we could improve your and others’ user experience, and continue improving our products, offerings and the overall performance of our Services;
5. To contact you with general or personalized service-related messages, as well as promotional messages that may be of specific interest to you (as further described in Section 6 below);
6. To facilitate, sponsor and offer certain events, contests and promotions;
7. To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
8. To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services, or for any other purpose; and
9. To comply with applicable laws and regulations.

1. Data Location & Retention

Data Location: Your personal data may be maintained, processed and stored by us and our authorized Service Providers (defined below) in multiple locations, including in the United Kingdom, the EU and other jurisdictions, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.

While privacy laws may vary between jurisdictions, OUNO App and its Service Providers are each committed to protect personal data in accordance with this Privacy Policy, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.

Data Retention: We will retain your personal data for as long as it is reasonably necessary for us to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our contractual terms and data retention policy.

Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at privacy@ounoapp.com.

 

1. Data Sharing

Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement) and where such disclosure is necessary to comply with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our Services.

Service Providers: We engage selected third-party companies and individuals to perform services complementary to our own. Such service providers hosting and server co-location services, communications and content delivery networks (CDNs), billing and payment processing services, data and cyber security services, fraud detection and prevention services, web and mobile analytics, e-mail, text messages and web/mobile notification distribution, monitoring and analytics services, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, call and session recording services, and our legal, financial and compliance advisors (collectively, “Service Providers“).

These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such limited purposes as determined in our agreements with them. Should you decide to directly engage with any of OUNO App’s Service Providers, please note that such engagement is beyond the scope of OUNO App’s Terms and Conditions and Privacy Policy, and will therefore be covered by our Service Provider’s terms and policies.

Our Service Providers shall be deemed as ‘data processors’ in circumstances where OUNO App assumes the role of ‘data controller’; and where OUNO App acts as the ‘data processor’ for our business customer, the Service Provider shall be deemed our ‘sub-processor’ (as further described in Section 9 below).

Third Party Websites and Services: Our Services may also include links to third-party websites, and integrations with third party services. Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are governed by such third party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such website and third-party services.

Sharing Personal Data with our Customers and their Users: We may share your personal data with the business customer owning the account to which you are subscribed as a user – including data and communications concerning your use of the Services or other interactions with us, but only in relation to that business account). In such cases, sharing such data means that the account’s administrator(s) or other individuals in your organization may access it on behalf of our business customer, and will be able to monitor and review data concerning the rides or deliveries you ordered via our Services, as well as access any personal data that was submitted by you or the individual for whom you ordered the ride or delivery.

Sharing data between Users and Driving Partners: in order to provide our Services, we are required to share certain details about users (name, phone, ride start and end point, pick-up time and ride related details entered as free text) and our drivers or couriers (name, phone, user score, current location, time of arrival estimation, car type/brand and plate number, hobbies and similar information) with each other.

Protecting Rights and Safety: We may share your personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of OUNO App, any of our users, partners or customers, or any members of the general public.

OUNO App Subsidiaries and Affiliated Companies: We may share personal data internally within our group of companies, for the purposes described in this Privacy Policy. In addition, should OUNO App or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, your personal data may be shared with the parties involved in such an event. If we believe that such change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

For the avoidance of doubt, OUNO App may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.

 

1. Cookies and Tracking Technologies

Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and called “Persistent Cookies”. We use both types.

We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the Services. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools.

Every browser allows you to manage your cookies preferences. Please bear in mind that disabling cookies may complicate or even prevent you from using certain parts of features of the Services.

For more information, please review our Cookie Policy.

We also use analytics tools such as Google Analytics. These tools help us understand your behavior on our Services, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of our google analytics is available at: www.google.com/policies/privacy/partners/;

Further information about your option to opt-out of google analytics services is available at: https://tools.google.com/dlpage/gaoptout.

Please note that if you get a new computer or device, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.

 

1. Communications

Service Communications: By creating an account and providing your phone number, you agree to receive text messages from Ouno. Message and data rates may apply. Message frequency varies.

Promotional Communications: We may also notify you about new features, additional offerings, better ways to use the Services, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, SMS, mobile notifications or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive such promotional communications, you may notify OUNO App at any time by filing THIS form, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.

 

1. Information Security

We and our hosting services implement systems, applications and procedures to secure your personal data, and to reduce the risks of theft, damage, loss of data, or unauthorized access or use of personal data. These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

 

1. Data Subject Rights

If you wish to exercise your rights under any applicable law, such as the EU General Data Protection Regulation (GDPR), to request access to, and rectification or erasure of your personal data held with OUNO App, or to restrict or object to such personal data’s processing, or to port such personal data – please contact us via privacy@ounoapp.com.

Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to better understand the nature and scope of the data to which your request pertains. Such additional information will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.

We may redact from the data which we will make available to you, any personal data or confidential information related to others.

 

1. Data Controller/Processor

Certain data protection laws and regulations, such as the GDPR, typically distinguish between two main roles for parties processing personal data: the “data controller”, who determines the purposes and means of processing; and the “data processor”, who processes the data on behalf of the data controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

OUNO App is the “data controller” of personal data pertaining to its users, drivers and couriers, customers, suppliers, visitors and prospects, and assumes the responsibilities of a data controller (solely to the extent applicable under law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data will assume the role of “data processor”.

OUNO App is the “data processor” of registration and deregistration data pertaining to users of business accounts (solely to the extent that such data is shared by our business customer during the onboarding process). In such instances, our business customer shall be deemed the “data controller” of such data, and OUNO App will process such data on the customer’s behalf, as its “data processor”, in accordance with its reasonable instructions, subject to our Terms and Conditions, this Privacy Policy, and the commercial and data processing agreements executed between OUNO App and such customers (as applicable). OUNO App’s Service Providers shall then act as designated sub-processors in these instances. OUNO App’s business customer will be responsible for meeting any legal requirements applicable to data controllers (such as obtaining their consent or establishing other legal basis for processing).

 

1. Additional Notices

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. We will provide a 10-day prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.

External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Services for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to OUNO App’s Services.

Our Services are not designed to attract children under the age of 16: We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at privacy@ounoapp.com

Data Protection Officer: OUNO App has appointed Privacy Team as our Data Protection Officer (DPO), for monitoring and advising on OUNO App’s ongoing privacy compliance and serving as a point of contact on privacy matters for data subjects and supervisory authorities. If you have any comments or questions regarding our Privacy Policy, if you have any concerns regarding your privacy, or if you wish to make a complaint about how your personal data is being processed by OUNO App, please contact privacy@ounoapp.com.

UK Representative: OUNO App (UK) Limited has been designated as OUNO App’s representative in the United Kingdom for data protection matters pursuant to Article 27 of the UK GDPR. OUNO App (UK) Limited may be contacted only on matters related to the processing of personal data. To make such an inquiry, please send an email to privacy@ounoapp.com, or contact OUNO App (UK) Limited by post at 17a Pall Mall Deposit, 124-128 Barlby Road London, W106BL United Kingdom. If you are situated in the UK, you also have the right to lodge a complaint with the Information Commissioner’s Office.

Questions, concerns or complaints: If you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal data held with us, please contact us at: privacy@ounoapp.com